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Child Safeguarding Policy

Review draft — not yet effective. This English text is available for public review before legal approval and translation. It does not replace an operative GEF safeguarding policy until an approved version takes effect.

Draft version: 1.0 Draft date: 24 October 2026

1. Purpose

Grassroots Economics Foundation (GEF) is committed to protecting children from abuse, exploitation, neglect, discrimination, and avoidable harm in connection with its work. This Policy establishes minimum safeguarding expectations for GEF programs, research, education, events, media, partnerships, and operations involving children.

This Policy is guided by the best interests of the child, the Constitution of Kenya, the Children Act, applicable data-protection law, and relevant safeguarding duties in the places where GEF works.

2. Scope

This Policy applies to GEF trustees, directors, staff, volunteers, interns, contractors, consultants, researchers, visitors, photographers, service providers, and partners when acting for GEF or participating in a GEF activity involving children.

Partners must maintain safeguards appropriate to their role and the activity. A contract or partnership must not be used to avoid GEF's responsibility to assess and address risks connected with its own work.

3. Definitions

For this Policy:

  • Child means anyone under 18 years old.
  • Safeguarding means preventing and responding to abuse, exploitation, neglect, unsafe conduct, and other avoidable harm.
  • Child abuse can be physical, sexual, emotional, economic, or digital and includes exploitation, neglect, grooming, trafficking, harmful labor, harassment, and harmful traditional or institutional practices.
  • Safeguarding concern means information or circumstances suggesting that a child has been harmed, may be at risk, or that a safeguard has failed.
  • Representative means a person to whom this Policy applies because they act for, work with, or participate in an activity on behalf of GEF.

4. Safeguarding principles

GEF and its representatives must apply these principles:

  1. Best interests. The child's safety, dignity, development, and best interests are a primary consideration.
  2. Do no harm. Activities are designed and changed to reduce foreseeable physical, emotional, social, economic, privacy, and digital risks.
  3. Non-discrimination. Every child receives protection without discrimination based on identity, background, ability, status, family, location, or belief.
  4. Participation. Children receive age-appropriate information and a genuine opportunity to express views about matters affecting them.
  5. Accountability. Concerns are taken seriously, recorded appropriately, and referred or investigated by people with the necessary authority and competence.
  6. Confidentiality with limits. Information is shared according to need, safety, and law. Confidentiality is not promised where disclosure is necessary to protect a child.
  7. No retaliation. A child or other person must not be punished for making a good-faith report or participating in a safeguarding process.

5. CLC App eligibility

The Cosmo-Local Credit App is restricted to people who are at least 18 years old and have reached the age of legal majority applicable to them. This Policy does not authorize a child to create or use an App account.

Do not create an account for a child, ask a child to control a Wallet or credential, or publish a child's personal data through the App unless GEF has established a separate lawful process with appropriate safeguarding, privacy, security, consent, and supervision. No such route is created by this Policy.

6. Expected conduct

Representatives must:

  • treat children with respect and use language and behavior appropriate to the child's age and context;
  • plan activities so that contact is observable, accountable, and appropriately supervised;
  • follow agreed consent, attendance, transport, communication, media, and emergency arrangements;
  • maintain appropriate professional and physical boundaries;
  • listen to concerns without blaming, pressuring, coaching, or making promises they cannot keep;
  • report a safeguarding concern promptly; and
  • challenge unsafe conduct in a way that does not create additional danger.

Representatives must not:

  • engage in sexual activity, sexual communication, grooming, exploitation, or a romantic relationship with a child;
  • use degrading, humiliating, discriminatory, threatening, violent, or exploitative language or conduct;
  • exchange money, gifts, employment, access, assistance, or favors for sexual, personal, political, or exploitative purposes;
  • employ or involve a child in unlawful, hazardous, coercive, or developmentally harmful work;
  • be alone with a child in an unobservable setting where this can reasonably be avoided;
  • take a child to a private home, vehicle, or overnight setting without an authorized and risk-assessed arrangement;
  • contact a child privately through personal accounts or devices contrary to the approved communication plan;
  • publish identifying information, precise location, images, or stories without the required authority and safety assessment; or
  • investigate an allegation personally unless formally assigned and qualified to do so.

7. Safer recruitment and engagement

Before assigning a person to a role involving children, GEF assesses the role and applies proportionate safeguards. These can include identity and reference checks, lawful background or criminal-record checks, interview questions, declarations, code-of-conduct acceptance, induction, supervision, and periodic review.

Selection decisions must consider the nature, frequency, location, and level of authority or unsupervised contact. A completed check does not replace supervision, reporting, or risk management.

Partners and contractors must demonstrate suitable recruitment, conduct, reporting, and response arrangements before beginning higher-risk activities involving children.

8. Training and supervision

Representatives receive safeguarding information appropriate to their role before contact with children. Training covers recognizing concerns, expected conduct, safe communication, consent, privacy, reporting, and emergency action.

People with designated safeguarding or investigative responsibilities receive additional training and access to specialist advice. Managers provide supervision and review whether safeguards are working in practice.

9. Activity and partner risk assessment

An activity involving children must assess foreseeable risks before it begins and when circumstances change. The assessment should address:

  • the child's age, ability, language, circumstances, and additional vulnerabilities;
  • location, travel, accommodation, physical access, supervision, and emergency support;
  • power imbalances, money, incentives, selection, employment, and benefits;
  • photography, interviews, research, data collection, mapping, and publication;
  • digital platforms, devices, direct messaging, online audiences, and permanent records;
  • partner capacity, complaints, referral pathways, and local services; and
  • risks to children arising from association with GEF, a community group, or another participant.

Higher-risk activity requires documented controls and approval by the accountable safeguarding role. An activity must be changed, paused, or cancelled where risk cannot be reduced to an acceptable level.

10. Participation, information, and consent

Children should receive truthful, age-appropriate information about an activity, what they are being asked to do, foreseeable risks, how information will be used, whether participation is optional, and how to ask for help or stop participating.

GEF obtains the child's agreement and any parent, guardian, or other authorization required by law and the activity. A signature does not make unsafe activity acceptable, remove the child's right to object, or replace an assessment of the child's best interests.

Refusing or leaving an optional activity must not result in retaliation or an undisclosed loss of essential support. Extra care is required where authority, dependency, payments, gifts, aid, education, or employment could make agreement feel compulsory.

11. Images, stories, research, and personal data

GEF collects and uses children's information only where there is a clear purpose, lawful authority, and suitable safeguard. The Data Protection Policy also applies.

Before recording or publishing a child's image, voice, story, work, identity, contact details, community affiliation, or location, the responsible team must consider consent, dignity, accuracy, future reuse, audience, digital permanence, and the risk of identification or harm.

GEF will, where appropriate:

  • avoid names, exact locations, school details, contact information, Wallet addresses, and other unnecessary identifiers;
  • use group, partial, staged, anonymized, or non-identifying material;
  • avoid images or stories that are degrading, sensational, misleading, or reveal a safeguarding concern;
  • explain that online material can be copied beyond GEF's control;
  • provide a practical contact for correction or removal from channels GEF controls; and
  • securely limit access to raw research, consent, case, and safeguarding records.

No child safeguarding record should be placed on a public blockchain.

12. Digital communication

Digital contact with children must use approved channels, a clear purpose, appropriate hours, and suitable oversight. Where practicable, a parent, guardian, responsible organization, or second authorized adult should be included or aware.

Representatives must not use disappearing messages, secret accounts, sexualized content, coercive monitoring, or private exchanges that prevent appropriate accountability. Personal devices and accounts should not be used where an approved organizational method is available.

Suspected online grooming, exploitation, threats, or non-consensual sharing must be reported promptly and handled without unnecessarily copying or circulating harmful material.

13. Reporting a concern

Report a safeguarding concern as soon as possible to [email protected] or to the designated safeguarding contact communicated for the activity.

If a child is in immediate danger or needs urgent medical help, contact the appropriate local emergency, medical, child-protection, or law-enforcement service first where it is safe to do so, then notify GEF.

A report should include only information reasonably necessary to respond, such as:

  • what happened or was observed;
  • when and where it happened;
  • who may be at risk;
  • what the child said, using their own words where possible;
  • any immediate action already taken; and
  • a safe way to contact the reporter.

Do not confront an alleged offender, promise secrecy, pressure the child to repeat an account, or conduct your own investigation. Preserve relevant information securely and share it only through the reporting process.

Anonymous reports will be considered, although limited information can affect the response. Knowingly malicious reports may be addressed, but a report made honestly will not result in retaliation merely because it is not substantiated.

14. Response and referral

GEF will prioritize immediate safety, acknowledge the concern where appropriate, restrict access or activity when necessary, and assign the matter to an accountable person without a conflict of interest.

The response can include specialist safeguarding advice, support for the child and family, preservation of records, contractual or disciplinary measures, and referral to a competent child-protection, medical, regulatory, or law-enforcement body. Decisions must consider the child's best interests, wishes, evolving capacity, safety, privacy, and applicable reporting duties.

An internal process does not replace a mandatory report or an independent authority's investigation. GEF will not mediate an allegation where mediation could compromise safety, evidence, rights, or accountability.

15. Confidentiality and records

Safeguarding information is restricted to people who need it for protection, response, oversight, support, or legal duties. Records must be accurate, factual, dated, securely stored, and separated from general program files where appropriate.

GEF retains safeguarding records according to purpose, risk, limitation periods, legal obligations, and the need to protect children or respond to future concerns. Access, sharing, and disposal must follow the Data Protection Policy and applicable law.

16. Partners and community accountability

Agreements for activities involving children must identify safeguarding responsibilities, reporting routes, conduct expectations, information-sharing limits, and the consequences of non-compliance.

GEF listens to children, parents, guardians, communities, and partners when designing accessible reporting and feedback processes. Community practice is considered respectfully but does not justify conduct that violates a child's rights or safety.

GEF may suspend an activity, restrict a representative, require corrective action, end a partnership, or report conduct to an authority where safeguards are absent or breached.

17. Review and contact

GEF reviews this Policy at least annually and after a significant incident, legal change, or material change in activities involving children.

Safeguarding reports and questions can be sent to:

Grassroots Economics Foundation
P.O. Box 1659-80108
Kilifi, Kenya
[email protected]

Privacy and data-rights questions should be sent separately to [email protected].